The NSW EPA released its draft Greenhouse Gas Assessment Guide for Large Emitters (the Guide), which set out how large emitters, those > 25,000 tpa CO2-e emissions must complete NSW Planning requirements including Greenhouse Gas Mitigation Plans (GHGMP) and EPA requirements - Climate Change Mitigation and Adaptation Plans (CCMAP). The Guide represents an expanded template for the requirements for smaller EPL holders for doing CCMAPs, so has quite broad implications. ASBG supports the general thrust of the Guide, especially it's the consideration of Scope 3 emissions as being encouraged but not required. ASBG identified three main issues with the Guide including:
- Avoidance of duplication and overlap with the Commonwealth systems, such as National Greenhouse and Energy Reporting and the Safeguard Mechanism and development of documents to identify where such reporting replaces parts of GHGMPs and CCMAPs.
- Excessive enforcement of NSW’s NSW Climate Change (Net Zero Future) Act 2023 targets, which may generate an uncompetitive environment for NSW EPL holding organisations from lower cost and higher CO2-e. ASBG explores various options where the export of NSW local jobs and importation of higher carbon intensity products could be avoided.
- Ensure the definitions used to account for carbon emissions are consistent and compatible with the Commonwealth’s and also the International Standards Organisation’s (ISO) series of ISO 14001 standards on greenhouse gases.
 ASBG Submission on the Draft Climate Change Assessment Requirements | 869 kB |
